My name is Mandy Hancock and I am the high risk energy organizer with Southern Alliance for Clean Energy. We are a
regional non-profit organization with members here in Florida, in FPL’s service region, and across the Southeast concerned
about the impacts energy choices have on our health, economy and environment. Thank you for having this meeting.
We have serious concerns about FPL’s push to build two new reactors here in Miami-Dade County that the Nuclear
Regulatory Commission (NRC) must address as they prepare the draft environmental impact statement (DEIS). The
uncertainties continue to escalate, putting ratepayers, taxpayers, and the environment at increasing risk. Turkey Point has a
long history of infractions with the NRC, including three violations in its storage of radioactive nuclear waste just last
month.1 With vast amounts of radioactive waste already onsite, allowing more reactors to be built that will generate more
waste is irresponsible when FPL cannot safely manage what has already been produced. Despite the NRC’s Waste
Confidence Rule, communities in South Florida do not have confidence in FPL’s ability to manage this toxic waste.
The NRC should be aware that FPL ratepayers aren’t happy about the tens of millions they have been forced to pay for in
advance given the pre-payment scheme in place to finance new reactors in Florida. And FPL is again asking the troubled
Florida Public Service Commission (PSC) for tens of millions more with hearings set for the end of August.
There are more affordable ways for FPL to meet energy demand while protecting the environment and tackling global
warming. As Southern Alliance for Clean Energy and the Natural Resource Defense Council testified to the PSC in 2009,
simply increasing energy efficiency goals by 1% could save enough energy to eliminate the “need” for new reactors, while
saving ratepayers money.2 Additionally, investing more resources in solar, wind and clean bio-energy instead of costly new
reactors would benefit FPL and offer economic development opportunities for Florida, without draining our water resources
or pocketbooks. The NRC must evaluate updated information using a combination of these sustainable energy choices,
including energy efficiency, before allowing FPL to commit billions of dollars, billions of gallons of water, and nearly an
entire decade or more to building these reactors when that time and money could be better spent on less risky options.
Energy efficiency measures preserve our water resources, save consumers money and also pose no health or safety risks to
the public. Florida utilities have significant resources to tap in these areas as outlined in a recent extensive report, “Energy
Efficiency in the South,” by Georgia Tech and Duke University3 and our report, “Yes We Can: Southern Solutions for a
National Renewable Standard.”4
Renewable energy technologies, such as solar and wind, do not require extreme manipulation of our precious water
resources. The Environmental Report overlooks the potential for FPL to pursue a combination of wind and solar resources
within its service territory and states that there is no renewable technology alternative that could mitigate the need for nuclear
power.5 The alternative analysis is based on the archaic assumption that base load power is needed. Last April, Federal
Energy Regulatory Commission Chief Jon Wellington told the U.S. Energy Association that saying we need base load energy
is like saying we need mainframe computers. The technology currently exists for distributed energy systems that negate the
need for base load power.6
Further, the NRC must use updated information to reevaluate FPL’s 2008 analysis for the new reactors in terms of the need
for power given the economic downturn and significant reduction in demand.

Water Impacts
The NRC needs to acknowledge that this area is an extremely sensitive hydrological environment. The history of the
Everglades and the current costly restoration projects illustrate the long-term shortsightedness that has scarred Florida’s
waterways. When comparing types of energy generation, nuclear power has higher rates of both water withdrawal and
consumption than coal and natural gas and far more than renewable energy sources, such as wind and solar. 7 The April 2010
report I mentioned earlier by Georgia Tech and Duke University examined energy efficiency in the South and illustrated
ways to substantially reduce energy needs, while simultaneously reducing water consumption. According to the report:
“In the North American Electric Reliability Council (NERC) regions in the South, 8.6 billion gallons of freshwater
could be conserved in 2020 (56% of projected growth in cooling water needs) and in 2030 this could grow to 20.1
billion gallons of conserved water (or 45% of projected growth).”8
Instead, we see FPL’s projected figures for water demand in 2025 to include a 35% increase for public and commercial needs
and a whopping 3224% increase for thermoelectric power generation.9 The NRC needs to fully evaluate less water intensive
energy alternatives—efficiency and renewables—including using a combination of these energy options. The NRC also
needs to analyze the impacts such a drastic increase in water demand from the power sector could cause to this area.
Cumulative Impacts
As the NRC is aware, FPL already operates three reactors here in Florida and is proposing to build two more. FPL also
proposes to build an onsite storage facility to deal with high level radioactive waste already over-flowing in the spent fuel
pools. This amount of radioactivity clustered in such a population-dense, hurricane-prone area could create significant safety
and health concerns for Floridians. The NRC must address these cumulative impacts to water resources and human health.
Miami-Dade County is an extremely dense population area with 1158 people per square mile.10 Although FPL and
Westinghouse state that the “probability of a severe accident is very low for the AP1000,”11 this reactor design has never
been built or operated anywhere in the world. Can they guarantee that an accident will never occur? Let’s remember that the
oil disaster Gulf communities are now grappling with was also supposed to be a very unlikely event. A recent technical report
by Mr. Arnold Gundersen, a nuclear engineer with decades of industry experience, raises serious concerns about the safety of
the AP1000 reactor design, concluding that the containment vessel is less safe than current reactors that have had a history of
containment failures.12 This concern, coupled with the high population density of the region, should be fully evaluated by the
NRC. This is especially urgent in light of FPL’s accident analysis scenarios, which assume that 95% of the population will be
evacuated if an accident occurs.13 In such a highly populated area, it seems unlikely that 95% of the population could be
evacuated in a timely enough manner to avoid exposure in the event of a severe accident. Would this be possible if a serious
storm or hurricane were threatening the area at the same time? I think not. A 1982 Congressional report estimated that if a
meltdown occurred at just one of the existing Turkey Point reactors it could cause 29,000 peak early fatalities, 45,000 peak
early injures, 4,000 peak cancer deaths, and $48.6 billion in property damage.14
In light of the ongoing, devastating BP oil disaster, the last thing Florida and this country needs is to approve another risky
energy technology such as the proposed Turkey Point reactors. We demand that utilities utilize technologies to create an
energy system that does not threaten public health and safety nor devour economic, environmental, and water resources. The
inherent power in the Earth’s environmental systems along with measures to reduce overall energy demand can provide the
energy needed without degrading ecosystems and depleting life-necessary resources. There is an opportunity to do things
differently and in smarter, non-radioactive ways. That opportunity must be seized for the sake of our communities and future
generations.
Thank you.
Mandy Hancock, 229-563-6090
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